SASless,
For the very good reason that it comes from:
GM2 OPS.GEN.150.A Instrument Flight Rules (IFR) operating minima
AERODROME MINIMA - CONTINUOUS DESCENT FINAL APPROACH (CDFA) – AEROPLANES
and describes, not only the continuous descent procedure, but also the perils of the approach without vertical guidance. For reason we have already enumerated, the ARA is not suited to the continuous descent approach; the beauty of this guidance material is that it examines the issue in great depth and provides advice in the cases where continuous descent procedures cannot be applied.
This is not just applicable to ARAs, the work that has been done on Point in Space (PinS) procedures can also put us in a position where continuous descent is not an option (i.e. where the MAPt is positioned to provide a missed approach in those cases where putting it closer to the heliport would raise it to an impractical level). In this case, there is a level approach segment (from the MAPt) which lead to a Descent Point (DP).
I hesitate to say this but there was no necessity for the invention of terms undertaken by DB (and in this thread); a reading of the Standard for the PinS in ICAO Doc 8186 (PANS OPS) would have provided enough clues. It was only when I had occasion to revisit the ICAO text (for an exchange of emails on hospital PinS procedures in France) that I remembered discussions leading to their provision.
Why is the guidance restricted to aeroplanes? You know as well as I do that helicopters are not considered to be real aircraft in the sense of IFR! Look at the lead in paragraph to the guidance:
Controlled Flight Into Terrain (CFIT) is a major causal category of accident and hull loss in commercial aviation. Most CFIT accidents occur in the final approach segment of non-precision approaches; the use of stabilised-approach criteria on a continuous descent with a constant, pre-determined vertical path is seen as a major improvement in safety during the conduct of such approaches. Operators should ensure that the following techniques are adopted as widely as possible, for all approaches;
and in cases where it is not appropriate:
Visual reference and path-control below MDA/H when not using the CDFA technique. In addition to the requirements stated in OPS.GEN.150 and its AMC material the pilot should have attained a combination of visual cues to safely control the aeroplane in roll and pitch to maintain the final approach path to landing. This should be included in the standard operating procedures and reflected in the operations manual.
(as for the reference to the
visual cues required for non-precision approaches - don't bother to look for them in OPS.GEN.150 they are not there. They have magically appeared in the text that was originally provided for 'commencement and continuation of approach' - i.e. the text in JAR-OPS that was concerned with the 'approach ban'.)
and also:
The operator should provide the flight crew with unambiguous details of the technique used (CDFA or not).
As for the question aimed at the regulator; they must answer for themselves. As must the operators who should, perhaps, be aware of this type of guidance.
Jim